Privacy Notice
Privacy Notice – Fairsquare Projects
1. Introduction
Fairsquare is committed to protecting the privacy of individuals who engage with our content and services. This Privacy Notice explains how we collect, use, disclose, and protect personal data in compliance with our responsibilities under the UK Data Protection Act 2018 and UK GDPR, while also recognising the journalism exemption provided under relevant legislation. Where individuals are based outside the UK, we aim to handle personal data consistently with the protections set out in this notice.
In this privacy notice, references to Fairsquare or to ‘we’ or ‘us’ are to Fairsquare Projects which is a registered company in England and Wales under number 11952483 and our address is Piano House, 9 Brighton Terrace, London SW8 8DJ, United Kingdom.
2. Information we collect
Personal data means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you visit our website or engage with us as a supporter, we may collect and process the following categories of personal data:
Information you provide as a supporter: including name, email address, postal code or country, and other contact details when you subscribe to our mailing list, sign a petition or other campaign action, contact us, engage with us on social media, or make a donation
Campaign action data: including the actions you take in support of our campaigns (such as petition signatures, emails to decision-makers, or event sign-ups), any comments you choose to share, and the campaigns you have engaged with
Automatically collected information: including IP addresses, cookies and similar identifiers, browsing activity, referring site, and device details when you visit our website or interact with our emails
3. How we get your information
We may collect your personal data in the following ways:
When you visit our website
When you engage with our social media platforms, including via advertising we run on platforms such as Meta (Facebook and Instagram) and Reddit
When you sign up for our newsletter, sign a petition, take a campaign action or make a donation, we get your data directly from you
4. Why we use your information
When you visit our website or engage with us as a supporter, we use your personal data for the following purposes:
To support your engagement in our campaigns, including delivering petitions and other campaign actions to their intended recipients
To send you newsletters and updates about our work where you have asked to receive them
To manage your donation
To analyse website usage and enhance user experience
To plan, deliver and measure the performance of advertising campaigns on platforms such as Meta and Reddit, including reaching audiences who may be interested in our work
To comply with our legal obligations
5. How the law allows us to use your personal data
We will only use your personal information when the law under data protection allows us to.
We may rely on the following lawful bases:
Where you have given your consent to process your personal data – for example, when you sign up to our newsletter, sign a petition, or accept non-essential cookies and advertising pixels on our website
Where we have decided the processing is necessary for our legitimate interests – for example, to understand how our website is used, to keep our services secure, and to measure the effectiveness of our campaigning and advertising in pursuit of our charitable mission
Where processing is necessary for us to perform a contract – for example, processing a donation
Where processing is necessary to comply with a legal obligation
6. Sharing of information
We may share your personal data with the following categories of recipient, who act as our data processors or, in some cases, as separate or joint data controllers:
Action Network – our campaigning and email platform, which we use to manage our mailing list and to host petitions and other campaign actions. Action Network is operated from the United States.
Donorbox and Stripe – Donorbox provides our donation form, and Stripe processes the resulting card payments and carries out related fraud and abuse prevention.
Google – we use Google Analytics 4 to understand how our website is used (with your consent), and Google reCAPTCHA to protect our forms from automated abuse. For reCAPTCHA, Google acts as our data processor and uses the information only to provide the security service.
Cloudflare – provides security, performance and bot mitigation for our website, including filtering automated and malicious traffic.
Meta Platforms (Facebook and Instagram) and Reddit – where you interact with our advertising or, with your consent, where our advertising pixels are active on our website. For the data collected through these pixels, we and the platform act as joint controllers; each platform then uses the information for its own purposes as an independent controller, as set out in its privacy policy (see sections 7 and 8).
We may also share data with other website hosting and technology service providers who help us operate our website, and with professional advisers or authorities where we are required to do so by law.
7. Cookies, advertising pixels and similar technologies
Our website uses cookies and similar technologies to keep the site working and secure, to analyse how it is used, and to measure the performance of our advertising. Some are essential for the site to function, while others are only used with your consent.
Some cookies and technologies are strictly necessary and are used without consent, because our website cannot operate safely without them. These include cookies that keep the site secure and protect our forms and donation process against fraud and automated abuse, provided by Cloudflare and Stripe. We also use Google reCAPTCHA to tell genuine visitors apart from automated bots on our forms. reCAPTCHA collects information about your device and how you interact with our forms, including your IP address, and sends it to Google, which acts as our data processor and uses the information solely to provide this security service. This involves a transfer of data to the United States (see section 8).
With your consent, we use Google Analytics to understand how our website is used, and the Meta Pixel and the Reddit Pixel to measure and deliver our advertising. The advertising pixels place cookies and similar identifiers on your device and share information with Meta and Reddit about your visit, such as the pages you viewed and the actions you took. This allows us to measure the effectiveness of our advertising on those platforms and to reach people who may be interested in our work. For the information collected through these pixels, we and the relevant platform act as joint controllers; each platform then uses the information for its own purposes as an independent controller, as set out in its privacy policy.
You can give, refuse or withdraw your consent to non-essential cookies and pixels at any time using the cookie banner on our website. You can review our cookie policy for more detail on the specific cookies we use.
8. International transfers
Several of our service providers are based in the United States or otherwise process personal data outside the UK and the European Economic Area (EEA). Where we transfer personal data internationally, we rely on a lawful transfer mechanism appropriate to each recipient:
For recipients certified under the EU-US Data Privacy Framework and its UK extension (the UK-US Data Bridge), we rely on that framework as the basis for the transfer. This applies to Google, Meta, Cloudflare and Stripe.
For recipients not covered by that framework, we rely on the UK International Data Transfer Agreement and, for EEA transfers, the EU Standard Contractual Clauses (with the UK Addendum where relevant), supported by a transfer risk assessment and any additional safeguards we consider necessary. This applies to Action Network and Reddit.
You can ask us for more information about the safeguards in place for any particular transfer using the contact details in section 11.
9. Data security and retention
We implement appropriate technical and organisational measures to protect personal data from unauthorised access, loss, or misuse.
Data retention periods vary depending on the purpose of processing, with data retained for as long as necessary for the purpose it was collected or as required by law. For example, we will keep your details on our mailing list until you unsubscribe or otherwise ask us to remove you.
10. Your rights
Subject to legal exemptions, you may have rights under applicable data protection laws, including:
The right to access, correct, or delete your personal data
The right to object to certain processing, including direct marketing and processing based on our legitimate interests
The right to restrict processing in certain circumstances
The right to data portability
The right to withdraw consent where processing is based on consent
The right to lodge a complaint with a data protection authority
To exercise your rights, please contact us using the details below. You are not required to pay any charge for exercising your rights.
Where we rely on your consent to process your personal information, you can withdraw your consent to our use of your data at any time. You can do this by contacting reboot@fairsq.org or by using the Unsubscribe function in any email we send you.
11. Contact us
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under UK GDPR.
If you have any questions about this Privacy Notice or how we handle personal data or would like to exercise a right, please contact:
Fairsquare Projects, Piano House, 9 Brighton Terrace, London SW8 8DJ, United Kingdom contact@fairsq.org
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. We will always do our very best to solve any problems you may have.
To contact the ICO, telephone their helpline on 0303 123 1113 or go to their website.
12. Updates to this privacy notice
We may update this privacy notice from time to time. Any changes will be posted on this page with an updated effective date.